Swiss Data Protection Representative
Switzerland's significantly revised Federal Act on Data Protection (revFADP), which came into force on 1 September 2023, represents a major modernisation of Swiss privacy law, bringing it into closer alignment with the EU GDPR while maintaining distinctly Swiss characteristics. Under Article 14 of the revised FADP, foreign organisations processing personal data of individuals in Switzerland may be required to appoint a Swiss-based Data Protection Representative when processing is regular, large-scale, and poses high risk to data subjects. For life sciences companies conducting clinical trials with Swiss sites, deploying medical devices in the Swiss market, or providing digital health services to Swiss patients, meeting this representation obligation is essential for regulatory compliance.
Swiss DPR Requirements & Obligations
The revised Swiss Federal Act on Data Protection( FADP), effective September 2023, introduces new representation requirements for international organisations. iliomad provides comprehensive Swiss-based representation services ensuring your compliance with Swiss data protection law.
Under Article 14 FADP, a foreign data controller must designate a Swiss representative if the organisation is domiciled outside Switzerland, processes personal data of individuals in Switzerland in connection with offering goods or services or monitoring their behavior, and the processing is regular, on a large scale, and poses a high risk to the personality or rights of data subjects. The representative acts as the Swiss contact point for both the authority and data subjects.
The Swiss representative serves as your official point of contact with the Federal Data Protection and Information Commissioner(FDPIC)-Switzerland's independent data protection supervisory authority. When the FDPIC conducts inquiries, requests information, or initiates proceedings related to your processing of Swiss personal data, the representative handles communications on your behalf with professionalism and regulatory expertise.
Under the FADP, the representative must hold and make available the controller's Record of Processing Activities when requested by the FDPIC. This requirement ensures that Swiss authorities can access information about your processing activities even when your organization is located outside Switzerland, supporting regulatory oversight and accountability.
Swiss data protection law requires that your representative's contact details be published in your privacy policy or other relevant documentation accessible to Swiss data subjects. This transparency requirement ensures individuals in Switzerland know how to contact your representative to exercise their rights or raise concerns about your data processing.
For life sciences companies processing personal data of Swiss clinical research participants, patients, or healthcare professionals, Swiss representation provides essential compliance infrastructure. Understanding the interplay between data protection law and Swiss clinical trial regulations is crucial for maintaining compliant research operations in the Swiss market.
Many organisations processing Swiss personal data also operate across the European Union, United Kingdom, and other jurisdictions with distinct data protection requirements. Effective Swiss representation requires coordination with these parallel obligations to ensure consistent compliance approaches while addressing Switzerland-specific requirements.
How iliomad Health Data Can Help You
At iliomad Health Data, we provide comprehensive Swiss representative services tailored specifically for life sciences and global operations. Our team understands the revised FADP requirements and the practical implications for organisations conducting clinical trials, deploying medical devices, or providing digital health services in the Swiss market. We ensure your Swiss compliance integrates seamlessly with your broader European and global privacy programs.
FAQs
Our frequently questions
A Swiss Data Protection Representative is a legally required contact point under Swiss FADP Article 14 for organizations outside Switzerland that process personal data of Swiss individuals. The Swiss Rep acts as your official interface with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and Swiss data subjects.
Organizations established outside Switzerland must appoint a Swiss Rep if they process personal data of Swiss individuals on a large scale, or process sensitive personal data (including health data) on a large scale. Most life sciences companies conducting Swiss clinical trials, selling products in Switzerland, or working with Swiss healthcare providers require a Swiss Rep.
As your Swiss Rep, we serve as your Switzerland-based contact point for the FDPIC and Swiss data subjects, handling authority communications, data subject requests, and regulatory correspondence. With compliance experience across 66 countries, we ensure your Swiss Rep function meets regulatory expectations while coordinating with any EU or other international compliance requirements.
Switzerland has its own independent data protection law (FADP) and supervisory authority (FDPIC), separate from EU GDPR. If you're established outside both Switzerland and the EU but process data in both jurisdictions, you typically need both a Swiss Rep and an EU Rep—we can serve in both roles.
Contact us through our website form or email directly. We'll schedule an initial consultation to understand your regulatory landscape, identify immediate priorities, and propose a tailored engagement that fits your timeline and budget.
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